There is a desire in electronic devices to include more memory capacity (i.e., memory storage units, memory cells, etc.) in smaller packages. Generally, design rules dictate the number of memory cells that may be included within a given physical area of a memory device. Design rules may include materials, dimensions, and spacing requirements that dictate how densely populated a memory device may be. Memory cell access devices (including contacts) may be one restricting factor to the size of a memory device or its density. For example, a desired level of current used to write to nonvolatile memory (NVM) elements may require a minimum size conducting path to the NVM elements in order to provide sufficient current to control the memory cells. Additionally, minimum spacing between elements is often necessary to electrically isolate the elements located within the memory device from each other. These issues become increasingly more important as the technology used for memory devices (e.g., 65 nm, 45 nm, 40 nm, 32 nm, 28 nm, etc.) becomes increasingly smaller.